Information

Covering note

This covering note is an appendix to the Table of ZAO Company Baxter (hereinafter - "the Baxter Company") containing the information on transferring the valuables to healthcare specialists and organizations for 2016 according to Clause 7.2 of the AIPM Good Practice Code (hereinafter - 'the Code").

Preparing the discovery and definition of valuables transferring in each category described in paragraphs 7.3.2 and 7.3.3 of the Code the Baxter Company applied the following methods and approaches.

I. The amounts of valuables transferring according to the categories of paragraphs 7.3.2 and 7.3.3 of the Code include the applied taxes (PIT, VAT).

II. The information on each fact of the valuables transferring according to the categories of paragraphs 7.3.2 and 7.3.3 of the Code is discovered individually in compliance with the effective legislation on personal data security.

III. The discovery of information on the valuables transferring to healthcare specialists.

a. The processing of the information on the valuables transferring is performed under condition of compliance with the requirements of the effective legislation of the Russian Federation governing the relations connected with the processing of personal data, in accordance to which the processing of the personal data should be performed by consent of the personal data subject to such processing provided that such consent may be withdrawn by the subject of the personal data.

b. In case when the valuables transferring to the healthcare specialists was not accompanied by an informed consent for an individual discovery, the information on such transferring of valuables is discovered in the general form for each accounting period. Such general discovery shows the information on each payment category concerning (i) a number of payees covered by such discovery in absolute terms and in percent of the total number of payees, and (ii) the total amount relating to valuables transferring to such payees.

c. In case of a withdrawal of the consent for an individual discovery from a healthcare specialist the Baxter Company stops processing the personified information in the aim of an individual discovery of the valuables transferring to the healthcare specialist submitting such withdrawal from the moment of receiving such withdrawal.

d. For eliminating any inaccuracy, renewal and removal of personal data a healthcare specialist can apply to the Baxter Company in any time in the following order: (а) by sending appropriate questions or complaints using a form of a complaint on violation of personal data processing procedure from the common Baxter site at: www.baxter.com/compliance ; (b) by sending an appropriate request filling a form of a complaint on violation of personal data processing procedure from the common site at: https://www.baxter.com/information/privacy/privacy_feedback.html; or (с) by applying to an employee of the International Department for Baxter data security through the Center for One Baxter on: 1-800-422-9837.

IV. The discovery of information on the valuables transferring to healthcare organizations.

a. The information on the valuables transferring to healthcare organizations is discovered individually taking into account the provisions of the effective Federal Law of July 27, 2006 No. 152-ФЗ On personal data which specify that personal data are any information relating directly or indirectly to a certain or defined natural person (a personal data subject) and accordingly requirements of this law on necessity of the consent cover the relations connected with the processing of personal data belonged exclusively to natural persons.

b. In case if a healthcare organization appoints a technical organizer, such technical organizer organizes events on the fund received from sponsors for the healthcare organization and under its control. The sponsorship fee paid to such technical organizer is subjected to discovery as a transfer of valuables performed to the corresponding healthcare organization that appointed this technical organizer.

c. If a number of healthcare organizations are event organizers, and a sponsorship agreement or a conference participation agreement is concluded only with a technical organizer, the distribution principal for the valuables transferring is an equal proportional division of the sponsorship fee between these healthcare organizations that is shown in the Table of the Baxter Company containing the information on transferring the valuables to healthcare specialists and organizations for 2016.

V. Conflict of interests.

The company confirms its commitment to the principal according to which the cooperation between pharmaceutical organizations and healthcare specialists must not result in the healthcare specialists' conflict of interests, namely between their professional duties and personal interests.